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05/22/2009 11:45 3032748329 <br />NN Banks and Gesso, LLC <br />N¦ <br />BANKS AND GESSO LLC PAGE 02/06 <br /> <br />720 Kipling St.,Suite117 <br />Lakewood, Colorado 80215 <br />(303) 274-4277 <br />Fax (303) 274-8329 <br />www.banksandgesso.com <br />Memorandum <br />To: Russ Means, DRM06/ <br />From: Alex Schatz <br />Re: Dick Casey 2009 R, M-1978-349, Response to May 18 Additional Review <br />Date: 22 May 2009 t,/ <br />c,=.. I, V E, - 'i 1) <br />MAY 2 ?009 <br />Division of R,ec.zrn.Zt- <br />M'??' and safety <br />The operator under Reclamation Permit M-1978-349, Old Castle SW Group, and this <br />firm as their permitting representative have reviewed the Division's letter of May 18, <br />2009, concerning technical review of the referenced TR submittal. With minor technical <br />clarifications, as requested and as set forth below, we generally concur with the <br />Division's analysis and believe the TR may be approved without further extension of the <br />review period. <br />Augmentation. In its analysis of reclamation contingencies, the Division cites a <br />estimated deficit of 16 "acre feet," as the difference between existing plus potential <br />groundwater exposure in the Chambers/Casey Pit complex (e.g., 17 + 21.9 acres = <br />approx. 39 surface acres) less the available substitute supply water by decree in Div. 5 <br />Water Court Case OOCW244 (23 surface acres). This deficit is, in fact, covered by a <br />separate TSSP and decree related to the Casey Pit (Div. 5 Water Court Case 03CW186 <br />and Gravel Well Permit 67081-F), which accounts for and provides substitute supply <br />water for 18 surface acres of groundwater exposure: Total permitted substitute supply <br />(augmentation) water exceeds the amount needed for both mining and reclamation <br />scenarios; however, because some aspects of the Casey Pit substitute supply plan are <br />still being assessed in the overall ownership transition to new management, the operator <br />commits that no groundwater will be exposed beyond losses already accounted for until <br />the sufficiency of Well 67081-F and the associated decree are confirmed or appropriate <br />modifications are in place. <br />backfill. Regarding backfill as a reclamation contingency, loads of fill material under this <br />option will be concentrated in horizontal footprint until exposed groundwater is <br />sufficiently buried to prevent evaporative depletion. Only after exposed groundwater is <br />minimized to the practical limit (based on available clean fill, operator timing to complete <br />reclamation, desire to maintain and reclaim ponds for a specific purpose, and other <br />factors) will fill be placed in lifts across a large horizontal area. As noted in the TR <br />submittal, the operator intends to account for all backfill contingencies in its revised <br />financial warranty, and the operator concurs that the proposed amount is sufficient. <br />Plant Substitutions. The operator agrees with the Division's comment that substitution of <br />reclamation plant materials will require the Division's review and approval as a Technical <br />Revision. <br />Please let me know if you have questions or comments. I may be reached by phone at <br />303-274-4277, or by electronic mail to aschatz _banksandaesso.com.